The Wales Flood and Coastal Erosion Committee called for input in relation to exploring opportunities to maximise resources for flood and coastal erosion risk management in Wales. RTPI Cymru submitted the following planning related comments:
We believe that a key challenge for the future will be to progress sustainable place making within those settlements where the risk of flooding is significant.
Links between planning and flood risk management need to extend beyond decisions on land use and Sustainable Drainage Systems to create resilient places, which can accommodate the natural processes of flooding. A revised Technical Advice Note (TAN)15 could have a key role in this. There will also be a need to focus the strategies and policies in Local Development Plans on this challenge as well as ensuring that the content of the relevant Area Statement is taken into account.
Where significant flood risks are present, all new development proposals will need to be assessed on their role in contributing to achieving resilience to flooding and coastal change. Proposals for redevelopment within settlements where significant flood risks are present will need particularly sensitive assessment. Regeneration policies will need to be carefully aligned with spatial planning and flood risk management. A revised TAN 15 will need to set the context for this.
Adequately resourced, collaborative working will be the key to involving a wide range of stakeholders. How this collaboration can be properly funded is an important discussion at the outset. The National Strategy for Flood and Coastal Erosion Risk Management along with an updated TAN 15, could helpfully identify a route to this goal of integration.
Future Wales – the National Development Framework (NDF) poses an opportunity to push boundaries in the longer term planning for Wales. We were pleased to see the latest version of the NDF recognise flood risk and climate change resilience, and we feel the plan could go further to address the issue of coastal adaption in future iterations. While we acknowledge that this currently might be beyond the term of the Plan, the NDF could be starting to set the agenda. Long-term sustainability goals, including climate change must remain priorities and at the forefront of planning for the future in Wales. Of course, adequate resourcing is vital. Local planning authorities have lost significant capacity in recent years. A well resourced, plan-led planning service can deliver corporate objectives, which, if properly encouraged and effectively organised can bring together objectives across services and help achieve local and national sustainable development and climate action goals.
The reassessment of long term funding is needed. The Wales Infrastructure Investment Plan (WIIP) may provide an opportunity to place investment into a broader strategic context for infrastructure funding, however additional mechanisms for funding will need to be found. Aligning the WIIP with Future Wales would be a significant step forward. Looking towards the longer term, a key opportunity could lie in the increase in land values which arises from public investment in infrastructure. Mechanisms to capture these increases and recycle them into further funding programmes could be investigated. Using existing sources of funding more effectively should also be considered, including a review of whether the Community Infrastructure Levy might be used more effectively and opportunities to co-ordinate resources with initiatives such as City Deal etc.
We believe the relationship between Place Plans and Community Flood Plans is yet to be fully explored. The capacity of Town and Community Councils and local communities is an important issue in relation to flooding and erosion and we believe with suitable resources, they have a greater role to play. This requires Town and Community Councils and the wider communities to be engaged both in the resilience efforts and through the planning system. Early engagement in the development plan and management processes are vital, incorporating Natural Resources Wales’ Community Flood Plans in any discussions.
